AQ_F_1800073_20220127_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Duke Energy Carolinas,LLC-Marshall Steam
Station
Inspection Report NC Facility ID 1800073
Date: 01/12/2022 County/FIPS: Catawba/035
Facility Data Permit Data
Duke Energy Carolinas,LLC-Marshall Steam Station Permit 03676/T58
8320 East NC Hwy 150 Issued 5/4/2021
Terrell,NC 28682 Expires 7/31/2022
Lat: 35d 35.8320m Long: 80d 57.9480m Class/Status Title V
SIC: 4911 /Electric Services Permit Status Active
NAILS: 221112/Fossil Fuel Electric Power Generation Current Permit Application(s)TV-Sign-501(b)(2)
Part II
Contact Data
Program Applicability
Facility Contact Authorized Contact Technical Contact
Joseph(Scott)La Sala Jeffrey Flanagan Daniel Markley SIP/Title V
Senior EHS Professional General Manager III Lead Environmental MACT Part 63: Subpart 6C, Subpart UUUUU,Subpart ZZZZ
[phone] [phone] Specialist
[phone] NSPS: Subpart IIII,Subpart 000,Subpart Y
Compliance Data
Comments:
Inspection Date 01/12/2022
Inspector's Name Melinda Wolanin
Inspector's Signature:Xe&adu Vo4w6e �3` Operating Status Operating
Compliance Status Compliance-inspection
Date of Signature: 1/27/2022 Action Code FCE
Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 264.89 3086.51 5991.98 85.09 2045.99 237.14 17985.28
2019 315.65 4877.96 8752.83 94.30 2167.26 293.68 23601.70
2018 356.93 3621.01 8836.06 102.16 2274.58 326.18 25612.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
04/13/2021 Compliance Method 5 MATS ES-1,ES-2
01/20/2021 Compliance Method 5 MATS ES-3
01/06/2021 Compliance Method 5 MATS ES-4

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 01/27/2022 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked IBEAM Complaint
X IBEAM Planning,Next Inspection Date 01/01/2023
Directions: From Mooresville,take Highway 150 West for approximately eight miles near Terrell. The
facility is located on the right. The facility has a sign in sheet with the guardhouse and another sign in sheet in
the lobby of the administrative building.
Safety Issues: Always be aware of construction and heavy truck traffic around the plant.
Safety Equipment: Hardhat, safety glasses, steel-toed shoes, and earplugs are required. A reflective vest is
also required in outside areas.
Lat/Long Coordinates: A review of the facility's coordinates on"Facilities Regulated by Air Quality"
indicates the facility's latitude and longitude coordinates are accurate and are locked in 1Beam.
Email: The email addresses in IBEAM were verified, and no changes are needed at this time.
Covid Safety: A mask must be worn at all times,regardless of vaccination status.
1. The purpose of this site visit was to conduct a full compliance evaluation and stack test observation. This
facility is a base load fossil/coal-fired/natural gas fired electricity generating plant with a total capacity of
2,090 megawatts (MW). The mailing address for the facility is 8320 East Highway 150,Terrell,NC
28682.
2. I conducted a compliance inspection at this facility on January 12,2022 and met with Mr. Scott LaSala,
Lead EHS Professional.
3. File Review:
A. The facility contact list was checked in IBEAM. All contacts are current.
B. The following files were reviewed prior to the inspection: the current permit No. 03676T58; the last
inspection report; correspondence since the last inspection; quarterly, semi-annual, and annual
reports.
C. Compliance History:
There have not been any complaints or violations for this facility in the last five years. The current
compliance status is discussed in Section 4 of this report.

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January 12,2022
Page 3
D. Operating Conditions established by Stack Testing.At the time of inspection, Grace Consulting was
conducting the Method 5 MATS/PM CEMS Relative Correlation Audit(RCA) for high particulate
on Unit 4. I observed the leak check between runs 2 and 3.
E. Records Required by Title V. During this inspection all records,required by the Title V permit were
reviewed. The records appeared to be in compliance,based on information submitted.
F. NESHAP/MALT Review. This facility is subject to NESHAP Subparts ZZZZ, 5U, and 6C and
NSPS Subparts Y,1111, and 000.
4. Section 2.1-Emission Source(s)and Control Devices(s) Specific Limitations and Conditions were observed
during this inspection:
A. One No. 2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx
concentric firing system, separated overfire air/lowered fired low-NOx technologies
(SOFA/LOFIR), and alkaline-based fuel additive (ID No. ES-1) and associated selective non-
catalytic reduction system (SNCR)NOx reduction system(ID No. CD-Ic (UISNCR)), sulfur
trioxide flue gas conditioning system(ID No. CD-2), electrostatic precipitator(ID No. CD-
3), and wet flue gas desulfurization system consisting of spray tower absorber(ID No. CD-
U1/2FGD)was observed as follows:
Parameter Observations
In operation No
Production rate -megawatts(MW)
Date/time last startup 1/7/2022
S02 1-hour building(lb/MBtu)
S02 24-hour building(lb/MBtu)
NOx 24-hour building(lb/MBtu)
NOx year to date(lb/MBtu) 0.273
Instantaneous opacity(%) 0.0*
Six-minute average opacity(%) 0.0*
Annual Average Opacity(AAO) 7.2
Date of last internal ESP/MAP inspection 10/5/2021
Environmentally forced outages since the last inspection None
SNCR Startup 4/19/06;Notification 4/21/06
Anhydrous ammonia injection ash conditioning system Startup 08/23/06;Notification 08/29/06
Wet flue gas desulfurization system installed Startup 05/13/07;Notification 05/15/07
* This was the last reading when the unit was in operation.
One No.2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx concentric firing
system, separated overfire air/lowered fired low-NOx technologies(SOFA/LOFIR),and alkaline-based fuel
additive(ID No.ES-2)and associated selective non-catalytic reduction system(SNCR)NOx reduction
system(ID No. CD-4c(U2SNCR)),sulfur trioxide flue gas conditioning system(ID No. CD-5),electrostatic
precipitator(ID No. CD-6),and wet flue gas desulfurization system consisting of spray tower absorber(ID
No. CD-U1/2FGD)was observed as follows:

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 4
Parameter Observations
In operation Yes
Production rate -megawatts(MW) 380.0
Date/time startup 1/4/2022
S02 1-hour building lb/MBtu) 0.09
S02 24-hour building(lb/MBtu) 0.14
NOx 24-hour building(lb/MBtu) 0.262
NOx year to date(lb/MBtu) 0.273
Instantaneous opacity 8.6
Six-minute average opacity 8.5
Annual Average Opacity(AAO) 8.6
Date of last internal ESP/MAP inspection 10/6/2021
Environmentally forced outages since the last inspection None
SNCR Startup 05/17/07;Notification 05/22/07
Anhydrous ammonia injection ash conditioning system Startup 08/23/06;Notification 08/29/06
Wet flue gas desulfurization system installed Startup 05/13/07;Notification 05/15/07
One No.2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx concentric firing
system, separated overfire air/lowered fired low-NOx technologies(SOFA/LOFIR),and alkaline-based
fuel additive(ID No. ES-3)and associated selective catalytic reduction system(SCR)NOx reduction
system(ID No. CD-7c(SCR)),electrostatic precipitator(ID No. CD-9(ESPnew)),and wet flue gas
desulfinization system consisting of spray tower absorber(ID No. CD-U3FGD)was observed as
follows:
Parameter Observations
In operation Yes
Production rate -megawatts(MW) 640.1
Date/time startup 1/5/2022
S02 I-hour building(lb/MBtu) 0.15
S02 24-hour building(lb/MBtu) 0.14
NOx 24-hour building(lb/MBtu) 0.106
NOx year to date(lb/MBtu) 0.124
Instantaneous opacity 0.0
Six-minute average opacity 0.1
Annual Average Opacity(AAO) 8.6
Date of last internal ESP/MAP inspection 3/15/2021
Environmentally forced outages since the last inspection No
SCR Startup 12/30/08
ESP modifications Startup 12/19/06;Notification 12/22/06
Wet flue gas desulfurization system installed Startup 03/15/07;Notification 03/21/07
NOTE: Unit 3 is now operating on natural gas only.
One No.2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx concentric firing
system, separated overfire air/lowered fired low-NOx technologies(SOFA/LOFIR),and alkaline-based
fuel additive(ID No. ES-4)and associated selective non-catalytic reduction system(SNCR)NOx
reduction system(ID No. CD-1 lc(U4SNCR)),sulfur trioxide flue gas conditioning system(ID No. CD-
12),powdered activated carbon system(ID No.CD-U4ActC),electrostatic precipitator(ID No. CD-13

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
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(ESPnew)),and wet flue gas desulfurization system consisting of spray tower absorber(ID No.CD-
U4FGD)was observed as follows:
Parameter Observations
In operation Yes
Production rate -megawatts (MW) 699.0
Date/time startup 1/6/2022
S02 1-hour building(lb/MBtu) 0.07
S02 24-hour building(lb/MBtu) 0.07
NOx 24-hour building(lb/MBtu) 0.285
NOx year to date(lb/MBtu) 0.212
Instantaneous opacity 1.1
Six-minute average opacity 0.4
Annual Average Opacity(AAO) 1.1
Date of last internal ESP/MAP inspection 3/16/2021
Environmentally forced outages No
ESP Modifications Startup 05/21/06;Notification 05/24/06
SNCR Startup 12/20/06;Notification 12/20/06
Wet flue gas desulfurization system installed Startup 10/30/06;Notification 11/08/06
Anhydrous ammonia injection ash conditioning system Startup 06/28/07;Notification 07/03/07
1. 15A NCAC 2D .0501(c): COMPLIANCE WITH EMISSION CONTROL STANDARDS
In addition to any control or manner of operation necessary to meet emission standards,any source of
air pollution shall be operated with such control or in such manner that the source shall not cause the
ambient air quality standards of 15A NCAC 2D .0400 to be exceeded at any point beyond the
premises on which the source is located.
Emissions of sulfur dioxide from these sources shall not exceed 0.56 lbs/mmBtu heat input in
accordance with the permit application of September 22,2003 and modeling analysis of October 29,
2003.
Monitoring/Recordkeeping
The permittee shall assure compliance by determining sulfur dioxide emissions in lbs/mmBtu using a
CEM system. Compliance with sulfur dioxide emission standards shall be determined by averaging
hourly CEM system values over a 24-hour block period beginning at midnight. To compute the 24-
hour block average,the average hourly values shall be summed, and the sum shall be divided by 24.
If any 24-hour block average exceeds the limit in the permit, or records are not maintained,the
permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(c).
Reporting
The permittee shall submit the CEM data showing the 24-hour daily block values in lbs/mmBtu for
each 24-hour daily block averaging period during the reporting period quarterly. All instances of
deviations from the requirements of this permit must be clearly identified.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
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CEM's Monitor Availability-The permittee shall submit a quarterly report of the sulfur dioxide
CEM systems monitor downtime reports, including monitor availability values(as calculated for 40
CFR Part 75)for the last hour of the reporting period.
Observed: The CEMs equipment was observed during the inspection and appeared to be operating
properly. The 24-hr block readings are shown in the following table:
4and
rce ID 24-hr
S02 Reading
(lbs/mmBtu)
PUnitsommon stack 1) 0.11
Unit 3 0.08
Unit 4 0.06
Each of the readings was less than the 0.56 lb/mmBtu limit.Units 2, 3,and 4 were in operation at the
time of the inspection. Reports were received on January 21,2021,April 27,2021,July 19,2021, and
October 29,2021. Compliance is indicated.
2. 15A NCAC 2D .0519: CONTROL OF NITROGEN OXIDES EMISSIONS
Emissions of nitrogen oxides from these sources shall not exceed:
i. 1.8 pounds per million Btu heat input when burning only coal;
ii. 0.8 pounds per million Btu heat input when burning only oil/or gas;
Emissions of nitrogen oxides from these sources when burning coal and/or oil shall be calculated by
the equation listed in the permit.
Monitoring/Recordkeeping
The Permittee shall ensure compliance with 15A NCAC 02D .0519 by determining nitrogen oxide
emissions in pounds per million Btu using a continuous emissions monitoring(CEM) system meeting
the requirements of 40 CFR Part 75 except that unbiased values may be used(missing data shall be
filled in accordance with 40 CFR Part 75 whenever the unit combusts any fuel). Compliance with
this emission standard shall be determined by averaging hourly continuous emission monitoring
system values over a 24-hour block period beginning at midnight. To compute the 24-hour block
average,the average hourly values(missing data shall be filled in accordance with 40 CFR Part 75)
shall be summed, and the sum shall be divided by 24. The minimum number of data points, equally
spaced,required to determine a valid hour value shall be determined by 40 CFR Part 75. If any 24-
hour block average exceeds the emission limit,the Permittee shall be deemed in noncompliance with
15A NCAC 02D .0519.
The Permittee shall maintain records of monthly coal and oil consumption(written or electronic
form) and shall submit such records within 30 days of a request by DAQ. The Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0519 if these records are not maintained.
Reporting
The permittee shall submit semi-annual reports of the CEM system data.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
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CEMS Monitor Availability-The permittee shall submit semi-annually the nitrogen oxide CEM
systems monitor downtime reports.
Observed: The facility is operating a CEM system as required. The following values were observed
during the inspection. The 24-hour NOx reading was below the limit for coal for the units operating
on coal (Units 2 and 4)and below the limit for natural gas for the unit operating on natural gas(Unit
3). Unit 1 was not in operation at the time of the inspection,
Source ID 24-hr
NOx Reading
Ibs/mmBtu
Units 1 and 2 (common stack 1) 0.262
Unit 3 0.106
Unit 4 0.285
The permittee uses oil to start the boilers after a shutdown and as the boiler gains heat then coal is
introduced. Once the proper boiler temperature is reached,then coal is the only fuel combusted. The
facility is maintaining records of the amount of coal and fuel oil combusted;I observed records
through December 2021. Fuel oil is used for start-up only. Reports were received on January 21,
2021,April 28,2021,July 19,2021,and October 29,2021,with compliance indicated.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
The Permittee shall either:
i. install,maintain,and operate a COMS for measuring the opacity of emissions,or
ii. install,maintain, and operate a PM CEMS.
The Permittee shall submit a written notification to the NCDAQ of intent to demonstrate compliance
using the option under Section 2.1 A3.a.i [COMS] of the permit or Section 2.1 A.3.a.ii [PM CEMS]
of the permit at least 30 calendar days before changing the compliance monitoring option.
Note: The facility is currently using the CEMS option for showing compliance.
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used, visible
emissions shall not be more than 40 percent opacity when averaged over a six-minute period except
that six-minute periods averaging not more than 90 percent opacity may occur not more than once in
any hour nor more than four times in any 24-hour period.
Testing
If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 02D
.2601 and General Condition JJ found in Section 3. If the results of this test are above the limit given
in Section 2.1 A.3.a. of the permit, the Permittee shall be deemed in noncompliance with 15A NCAC
02D .0521.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 8
Monitoring/Recordkeeping
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used, no monitoring
is required.
Reporting
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used, no reporting
is required.
All instances of deviations from the requirements of this permit must be clearly identified.
Observed: The facility is operating the CEMS as required,and the opacities are shown in the data
tables under Section A of this inspection report. Mr. La Sala has previously stated that the bypass
stacks are no longer used as an exhaust. The bypass stacks for Units 3 and 4 have been blocked. The
bypass stacks for Units 1 and 2 have a damper and is used as air intake to cool the boilers. The facility
has submitted the required reports. Compliance is indicated.
4. 15A NCAC 2D .0536: PARTICULATE EMISSIONS FROM ELECTRIC UTILITY BOILERS
Particulate emissions from the utility boilers shall not exceed the following:
Units 1 and 2 Boilers -0.20 lbs/mmBtu heat input each
Units 3 and 4 Boilers -0.18 lbs/mmBtu heat input each
The permittee shall obtain an air permit before installing or enabling Energy Management System
(EMS)capability.
Monitoring/Recordkeeping
A stack test shall be conducted for particulate matter in accordance with Method 5 or Method 5B of
Appendix A of 40 CFR Part 60 once per calendar year. In the event that a boiler exceeds 80 percent
of its particulate emission limit during the stack test,the permittee shall schedule and conduct another
stack test within 6 months.Upon demonstration that the source is operating under 80 percent of its
particulate limit, as shown by three consecutive semiannual stack tests,the source may resume annual
stack tests.
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] of the permit is used,
compliance with the particulate limit in Section 2.1.A.4.a of the permit shall be demonstrated using
the PM CEMS. A measured exceedance of the pounds per million Btu heat input values below shall
be a violation of the corresponding emission standards in Section 2.LAA.a. of the current permit.
Units 1 and 2 Boilers as CSO1 - 0.030 pounds per million Btu heat input (30-boiler operating day
rolling average) or 0.30 pounds per MWh (30-boiler operating day rolling
average)
Unit 3 Boiler- 0.030 pounds per million Btu heat input(30-boiler operating day rolling average)
or 0.30 pounds per MWh(30-boiler operating day rolling average)
Unit 4 Boiler- 0.030 pounds per million Btu heat input(30-boiler operating day rolling average)
or 0.30 pounds per MWh(30-boiler operating day rolling average)

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 9
i. The Permittee shall install, certify, operate, and maintain a PM CEMS and record the output of
the PM CEMS according to the applicable Maximum Achievable Control Technology (MACT)
standards in §63.10010(i) of 40 CFR Part 63 Subpart UUUUU, as specified in Section
2.I.A.16.f£ The PM CEMS shall meet the requirements of Performance Specification PS-I I of
Appendix B of 40 CFR Part 60. The Permittee shall have on file with the director an approved
quality assurance program and shall submit to the director within the time period of his request
for his approval a revised quality assurance program to include the provisions of 40 CFR 60,
Appendix F,Procedure 2 for the PM CEMS.
ii. The PM emission rate shall be determined based on a 30-boiler operating day rolling average of
the hourly arithmetic average emissions concentrations using the CEMS outlet data for each
boiler operating day (as defined below), except for data obtained during periods of startup or
shutdown. Periods of malfunction shall be included in the emissions calculations.
iii. Data from the PM CEMS shall be reduced to 1-hour averages computed from four or more data
points equally spaced over each 1-hour period, except during periods when calibration, quality
assurance, or maintenance activities pursuant to provisions of 40 CFR Part 63 are being
performed. During these periods, a valid hourly average shall consist of at least two data points
with each representing a 15-minute period. Alternatively, an arithmetic or integrated 1-hour
average of CEMS data may be used. Time periods for averaging are defined in§63.2.
iv. PM CEMS monitor availability shall be calculated and reported.
v. The Permittee shall record the output of the PM CEMS as specified in Section 2.1.A.16.hh of the
permit.
If the results of the arithmetic 30-boiler operating day rolling average PM CEMS concentration
exceeds the limit in this section or any of the above requirements are not met, the Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0536.
The collected flyash shall not be reinjected into the electric utility boilers (ID Nos. ES-1 through ES-
4). If the collected flyash is reinjected into these boilers, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0536.
Reporting
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used,the Permittee
shall submit excess emissions and monitoring system performance reports for PM in accordance with
the reporting requirements given in Section 2.I.A.7.d no later than January 30 of each calendar year
for the preceding three-month period between October and December, April 30 of each calendar year
for the preceding three-month period between January and March, July 30 of each calendar year for
the preceding three-month period between April and June, and October 30 of each calendar year for
the preceding three-month period between July and September. The compliance report shall include,
at a minimum, the information required in 40 CFR 63.10 and contain the information specified in
Section 2.1 A.16.xx, along with all 30-boiler operating day rolling average excess emissions (pounds
per million Btu or pounds per MWh) using the CEMS outlet data, including periods exempted during
periods of startup and shutdown.
The results of any stack test shall be reported within 30 days,and the test report shall be submitted within
60 days after the test.

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January 12,2022
Page 10
All instances of excess emissions must be clearly identified.
Observed: Particulate testing was conducted on Units 1 and 2(Common Stack 1 (CS 1))on April 13,
2021, on Unit 3 on January 20,2021,and on Unit 4 on January 6,2021. The results were reviewed
and accepted by the Stationary Source Compliance Branch(SSCB). The facility is currently testing
for 2022.
The CEMS was observed during the inspection and appeared to be operating properly.
The flyash is not reinjected into the boilers. Instead,the flyash is transferred to silo,transported
offsite,or landfilled.
The facility has submitted the required CEMS reports. Compliance is indicated.
5. 15A NCAC 2D .0536: ANNUAL AVERAGE OPACITY FOR ELECTRIC UTILITY
BOILERS
Visible emissions from the utility boiler units shall not exceed 20 percent annual average opacity.
The average is the sum of the measured non-overlapping six-minute averages of opacity determined
only while the unit is in operation divided by the number of such measured non-overlapping six-
minute averages. Start-up, shutdown, and non-operating time shall not be included in the annual
average opacity calculation,but malfunction time shall be included.
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used,the Permittee
shall calculate each day an annual average opacity value for the most recent 365-day period ending
with the end of the previous day. The average is the sum of the measured non-overlapping one-hour
averages of opacity determined only while the unit is in operation divided by the number of such
measured non-overlapping one-hour averages. Start-up, shut-down, and non-operating time shall not
be included in the annual average opacity calculation,but malfunction time shall be included. The
hourly opacity values shall be determined using the PM CEMS hourly average output values as
outlined in the permit.
For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used,the Permittee
shall submit a report showing the calculated annual average opacity of each unit and the annual
average opacity limit for each day during the reporting period no later than January 30 of each
calendar year for the preceding three-month period between October and December, April 30 of each
calendar year for the preceding three-month period between January and March, July 30 of each
calendar year for the preceding three-month period between April and June, and October 30 of each
calendar year for the preceding three-month period between July and September. All instances of
deviations from the requirements of this permit must be clearly identified.
Observed: The facility is using CEMS as their compliance option. The permittee is submitting
quarterly reports as required. The reports are reviewed by the SSCB. Compliance is indicated.
6. 15A NCAC 2D .0535: EXCESS EMISSIONS REPORTING AND MALFUNCTIONS
All electric utility boiler units shall have a malfunction abatement plan approved by the Director as
specified in 15A NCAC 2D .0535(d). The permittee shall maintain logs to show that the operation
and maintenance parts of the malfunction abatement plan are implemented.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 11
Observed: The facility has the required malfunction abatement plan(MAP), and logs are being
maintained onsite. See data table under Section 4.A of this review for MAP inspection dates.
Compliance is indicated.
7. 15A NCAC 2D .0606: SOURCES COVERED BY APPENDIX P OF 40 CFR PART 51
(CONTINUOUS OPACITY MONITORING AND EXCESS EMISSIONS)
The quarterly excess emissions (EE) reports shall be used as an indication of good operation and
maintenance of the electrostatic precipitators. These sources shall be deemed to be properly operated
and maintained if the percentage of time the PM emissions, calculated on a one-hour average, greater
than 0.030 pounds per million Btu heat input for Units 1 and 2 Boilers as CS 01, for Unit 3 Boiler,
and for Unit 4 Boiler does not exceed 3.0 percent of the total operating time for any given calendar
quarter, adjusted for monitor downtime (MD) as calculated in Section 2.1.A.7.a of the permit, except
that Total Excess Emission Time contains all one-hour periods greater than 0.030 pounds per million
Btu heat input. In addition, these sources shall be deemed to be properly operated and maintained if
the %MD does not exceed 2 percent for any given calendar quarter as calculated as shown in the
permit.
The Permittee shall use a(CEMS)to monitor and record sulfur dioxide emissions. Continuous emissions
monitoring and recordkeeping of sulfur dioxide shall be performed as described in Paragraphs 2 and
3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet the
minimum specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51.
The quarterly excess emissions (EE) reports required under Appendix P of 40 CFR Part 51 shall be
used as an indication of good operation and maintenance of the flue gas desulfurization scrubbers.
These sources shall be deemed to be properly operated and maintained if sulfur dioxide emissions do not
exceed 0.56 pounds per million Btu calculated on a 24-hour basis. Compliance with the sulfur dioxide
emission standard is determined by averaging hourly continuous emission monitoring system values over
a 24-hour block period beginning at midnight.To compute the 24-hour block average,the average hourly
values are summed, and the sum is divided by 24. A minimum of four data points, equally spaced, is
required to determine a valid hour value unless the continuous emission monitoring system is installed to
meet the provisions of 40 CFR Part 75. If a continuous emission monitoring system is installed to meet
the provisions of 40 CFR Part 75,the minimum number of data points is determined by 40 CFR Part 75.
In addition, these sources shall be deemed to be properly operated and maintained if the %MD does
not exceed 2 percent for any given calendar quarter as calculated as shown in the permit.
Reporting
The Permittee shall submit the excess emissions and monitor downtime reports as required under
Appendix P of 40 CFR Part 51 no later than January 30 of each calendar year for the preceding three-
month period between October and December, April 30 of each calendar year for the preceding three-
month period between January and March, July 30 of each calendar year for the preceding three-
month period between April and June, and October 30 of each calendar year for the preceding three-
month period between July and September as shown below. Reporting shall be in accordance with
Paragraphs 4 and 5.1 of Appendix P of 40 CFR Part 51.
i. For periods when the compliance option under Section 2.1 A.3.a.ii [PM CEMS] is used, excess
PM emissions are defined as any one-hour average greater than 0.030 pounds per million Btu heat
input for Units 1 and 2 Boilers as CS01, for Unit 3 Boiler, and for Unit 4 Boiler. The quarterly
report shall include the number of hours each day and the percent of operating hours during the

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Page 12
quarter with average PM emissions recorded by the PM CEMS greater than the concentration that
corresponds to 0.030 pounds per million Btu.
ii. Monitor downtime includes periods where there was no visible emission (COMS) or particulate
(PM CEMS)monitoring during monitor bypass as described in the permit.
iii. For sulfur dioxide, excess emissions are defined as greater than 0.56 pounds per million Btu
calculated on a 24-hour block average basis.
iv. All instances of deviations from the requirements of this permit must be clearly identified
Observed: The facility is using the CEMS option to show compliance. The CEMS was observed
during the inspection and appeared to be operating properly. Quarterly reports were submitted on
January 21,2021,April 28,2021,July 19,2021,and October 29,2021. Compliance is indicated.
Federally-Enforceable Only
8. CROSS STATE AIR POLLUTION RULES (CSAPR) PERMIT REQUIREMENTS
For the four boilers(ID Nos. ES-1 thru ES-4),the Permittee shall comply with all applicable
requirements of 40 CFR Part 97, Subpart AAAAA"CSAPR NOx Annual Trading Program", Subpart
BBBBB "CSAPR NOx Ozone Season Trading Program", and Subpart CCCCC "CSAPR S02 Group
1 Trading Program".
Observed: Under this rule, each of the units at this facility is considered a"large electric generating
unit",per 40 CFR 52.34. This rule and all requirements thereof are considered Federally-Enforceable
only. Compliance will be determined by the US EPA,not the NC DAQ.
9. Reserved
10. Reserved
11. Reserved
12. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING for 15A NCAC 02D
.0536: PARTICULATE EMISSIONS FROM ELECTRIC UTILITY BOILERS*
*This Section applies only during periods when the compliance option under Section 2.1 A.3.ad[COMS]
is used
Observed: The facility is using CEMS to show compliance with particulate emissions limits.
Compliance is indicated.
13. Reserved
14. 15A NCAC 2Q .0317 AVOIDANCE CONDITIONS FOR PSD
In order to avoid applicability of 15A NCAC 2D .0530(g),the PM/PM10 emissions from Unit 4
boiler(ES-4) shall be less than 15 tons per consecutive 12-month period, attributable to injecting
powdered activated carbon.

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Monitoring/Recordkeeping
The amount of injected powdered activated carbon in Unit 4 boiler(ES-4) shall not exceed 9,000,000
lbs per year. The permittee shall keep monthly records of the amount of powdered activated carbon
injected.
Reporting
The permittee shall submit a semi-annual report of monitoring and recordkeeping activities that
include the monthly amount of powdered activated carbon injected in the Unit 4 boiler and the
emissions for the previous 17 months.
Observed: As stated in a previous inspection report, activated carbon was used in June and July
2016 but has not been used since. Monthly records and the reports received January 21, 2021 and July
19,2021 reflect this. Compliance is indicated.
15. 15A NCAC 2Q .0317 AVOIDANCE CONDITIONS FOR SOURCES IN NONATTAINENT
AREAS
In order to avoid applicability of 15A NCAC 2D .0531(f),the PM2.5 emissions from Unit 4 boiler
(ES-4) shall be less than 10 tons per consecutive 12-month period, attributed to injecting powdered
activated carbon.
Monitoring/Recordkeeping
Monitoring/recordkeeping requirements in Section 2.1 A. 14.c. of the air permit shall be sufficient to
assure compliance with 15A NCAC 2D .0531.
Reporting
Reporting requirements in Section 2.1 A. 14.d. of the air permit shall be sufficient to assure
compliance with 15A NCAC 2D .0531.
Observed: Compliance with this section is demonstrated by showing compliance with Section
2.1.A.14 of the air permit.
16. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (40 CFR
PART 63 SUBPART UUUUU)
a. The Permittee shall comply with all applicable provisions, including the requirements for emission
limitations, work practice standards, operating limits, testing and initial compliance, continuous
compliance, monitoring, recordkeeping, notification, and reporting, contained in Environmental
Management Commission Standard 15A NCAC 02D .1111 Maximum Achievable Control
Technology (MACT) as promulgated in the most current version of 40 CFR Part 63 Subpart
UUUUU, "National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric
Utility Steam Generating Units"and Subpart A General Provisions.
Emission Limitations and Work Practice Standards
b. Except as provided under Section 2.1 A.16.c of the permit,the Permittee shall:

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i. limit the emissions of filterable particulate matter (PM) to 3.0E-2 lb/MMBtu or 3.0E-1 lb/MWh;
or limit the emissions of total non-Hg HAP metals to 5.0E-5 lb/MMBtu or 5.0E-1 lb/GWh; or
limit the emissions of individual HAP metals to the limits listed in the permit.
ii. limit the emissions of hydrogen chloride(HCI)to 2.0E-3 lb/MMBtu or 2.0E-2 lb/MWh; or
limit the emissions of sulfur dioxide(SO2)to 2.0E-1 lb/MMBtu or 1.5E0 lb/MN".
iii. limit the emissions of mercury(Hg)to 1.2E0 lb/TBtu or 1.3E-2 lb/GWh.
c. As an alternative to meeting the requirements of §63.9991(a)(1) for filterable PM, SO2, HF, HCI,
non-Hg HAP metals, or Hg on an EGU-specific basis as described in paragraph a above, the
Permittee may choose to demonstrate compliance by using emissions averaging as described in
§63.10009(a)(2) among existing EGUs in the same subcategory. If this option is selected for
mercury,the Permittee shall limit the concentration of mercury to 1.0 lb/TBtu or 1.1E-2 lb/GWh.
d. During periods of startup of an EGU:
i. The Permittee has chosen to comply using the following work practice standards, by choosing to
comply using paragraph(1)of the definition of"startup"in§63.10042, defined as follows.
Startup means either the first-ever firing of fuel in a boiler for the purpose of producing
electricity, or the firing of fuel in a boiler after a shutdown event for any purpose.
Startup ends when any of the steam from the boiler is used to generate electricity for
sale over the grid or for any other purpose (including on site use). Any fraction of an
hour in which startup occurs constitutes a full hour of startup.
The Permittee shall operate all CMS during startup, except during periods of bypass of the main
stack as provided in §63.10010(a)(4). For startup of a unit, clean fuels must be used as defined in
§63.10042 for ignition. Once the unit converts to firing coal,the Permittee shall engage all of the
applicable control technologies except the SCR. The Permittee shall start the SCR system
appropriately to comply with relevant standards applicable during normal operation. The
Permittee shall comply with all applicable emissions limits at all times except for periods that
meet the applicable definitions of startup and shutdown in Subpart UUUUU. The Permittee shall
keep records during startup periods.
ii. If the Permittee chooses to use just one set of sorbent traps to demonstrate compliance with the
applicable Hg emission limit,the Permittee shall comply with the limit at all times; otherwise,the
Permittee shall comply with the applicable emission limit at all times except for startup and
shutdown periods.
iii. The Permittee shall collect monitoring data during startup periods, as specified in §63.10020(a)
and (e). The Permittee shall keep records during startup periods, as provided in §§63.10032 and
63.10021(h). The Permittee shall provide reports concerning activities and startup periods, as
specified in §§63.10011(g), 63.10021(i), and 63.10031. The Permittee shall provide reports
concerning activities and startup periods, as specified in §63.10011(g) and §63.10021(h) and (i).
All periods of bypass of the main stack shall be reported as deviations as provided in
§63.10010(a)(4)(ii).
e. During periods of shutdown of an EGU:

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i. The Permittee shall operate all CMS during shutdown, except during periods of bypass of the
main stack as provided in §63.10010(a)(4). The Permittee shall also collect appropriate data and
shall calculate the pollutant emission rate for each hour of shutdown for those pollutants for
which a CMS is used. While firing coal during shutdown, the Permittee shall vent emissions to
the main stack(s) and operate all applicable control devices and continue to operate those control
devices after the cessation of coal being fed into the EGU and for as long as possible thereafter
considering operational and safety concerns. In any case, the permittee shall operate the controls
when necessary to comply with other standards made applicable to the EGU by a permit limit or a
rule other than Subpart UUUUU and that require operation of the control devices. All periods of
bypass of the main stack shall be reported as deviations as provided in §63.10010(a)(4)(ii).
ii. If, in addition to the fuel used prior to initiation of shutdown, another fuel must be used to support
the shutdown process,that additional fuel shall be one or a combination of the clean fuels defined
in §63.10042 and shall be used to the maximum extent possible taking into account
considerations such as not compromising boiler or control device integrity.
iii. The Permittee shall comply with all applicable emission limits at all times except during startup
periods and shutdown periods at which time the Permittee shall meet the work practice standards.
The Permittee shall collect monitoring data during shutdown periods, as specified in
§63.10020(a). The Permittee shall keep records during shutdown periods, as provided in
§§63.10032 and 63.10021(h). The Permittee shall provide reports concerning activities and
shutdown periods, as specified in §§63.1001 l(g), 63.10021(i),and 63.10031.
General Compliance Requirements
f. The Permittee shall comply with the General Provisions as applicable pursuant to Table 9 to Subpart
UUUUU.
g. The Permittee shall be in compliance with the emission limits and operating limits in Subpart
UUUUU. These limits shall apply at all times except during periods of startup and shutdown;
however, for coal-fired EGUs, the Permittee shall be required to meet the work practice requirements
in Table 3 to Subpart UUUUU during periods of startup or shutdown.
h. At all times, the Permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good
air pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the EPA
Administrator which may include, but is not limited to, monitoring results, review of operation and
maintenance procedures,review of operation and maintenance records, and inspection of the source.
i. For coal-fired units, initial performance testing is required for all pollutants for the affected EGUs to
demonstrate compliance with the applicable emission limits.
j. The Permittee shall demonstrate compliance with the filterable particulate matter(PM) emission limit
through an initial performance test and shall monitor continuous performance through use of a PM
continuous emissions monitoring system(PM CEMS).
k. The Permittee may demonstrate initial and continuous compliance by installing and operating a sulfur
dioxide (SO2) CEMS installed and operated in accordance with 40 CFR Part 75 to demonstrate
compliance with the applicable SO2 emissions limit.

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1. The Permittee shall demonstrate initial and continuous compliance through use of a Hg CEMS or a
sorbent trap monitoring system in accordance with Appendix A to the Subpart.
m. As part of demonstration of continuous compliance, the Permittee shall perform periodic tune-ups of
the affected EGUs, according to §63.10021(e).
n. On or before the date an EGU is subject to Subpart UUUUU, the Permittee shall install, certify,
operate, maintain, and quality-ensure each monitoring system necessary for demonstrating
compliance with the work practice standards for PM during startup periods and shutdown periods.
The Permittee shall collect,record, report, and maintain data obtained from these monitoring systems
during startup periods and shutdown periods.
o. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the general
compliance requirements in Sections 2.1 A.16.f through n above are not met.
Continuous Compliance Requirements
p. The Permittee shall monitor and collect data according to §63.10020.
q. The Permittee shall operate the monitoring system and collect data at all required intervals at all times
that the affected EGU is operating, except for periods of monitoring system malfunctions or out-of-
control periods (see §63.8(c)(7)) and required monitoring system quality assurance or quality control
activities, including, as applicable, calibration checks and required zero and span adjustments. The
Permittee is required to affect monitoring system repairs in response to monitoring system
malfunctions and to return the monitoring system to operation as expeditiously as practicable.
r. Except for periods of monitoring system malfunctions or monitoring system out-of-control periods,
repairs associated with monitoring system malfunctions or monitoring system out-of-control periods
and required monitoring system quality assurance or quality control activities including, as
applicable, calibration checks and required zero and span adjustments, failure to collect required data
is a deviation from the monitoring requirements.
s. The Permittee shall demonstrate continuous compliance with each emissions limit, operating limit,
and work practice standard in Tables 2 and 3 to Subpart UUUUU that applies to the affected EGU,
according to the monitoring specified in Table 7 to Subpart UUUUU and paragraphs (b) through (g)
of§63.10021(a).
t. Except as otherwise provided in §63.10020(c), if the Permittee uses a CEMS to measure SO2, PM,
HCI, HF, or Hg emissions, or uses a sorbent trap monitoring system to measure Hg emissions, the
Permittee shall demonstrate continuous compliance by using all quality-ensured hourly data recorded
by the CEMS (or sorbent trap monitoring system) and the other required monitoring systems (e.g.,
flow rate, CO2, 02, or moisture systems) to calculate the arithmetic average emissions rate in units of
the standard on a continuous 30-boiler operating day (or, if alternate emissions averaging is used for
Hg, 90-boiler operating day) rolling average basis, updated at the end of each new boiler operating
day. The Permittee shall use Equation 8, shown in the permit, to Subpart UUUUU to determine the
30-(or, if applicable, 90-)boiler operating day rolling average.
u. Conduct periodic performance tune-ups of the EGUs, as specified in paragraphs (e)(1) through(9) of
§63.10021. For the first tune-up, the Permittee may perform the burner inspection any time prior to
the tune-up or delay the first burner inspection until the next scheduled EGU outage provided the

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Page 17
requirements of §63.10005 are met. Subsequently, the Permittee shall perform an inspection of the
burner at least once every 36 calendar months unless the EGU employs neural network combustion
optimization during normal operations in which case an inspection of the burner and combustion
controls shall be performed at least once every 48 calendar months. If the EGU is offline when a
deadline to perform the tune-up passes, the tune-up work practice requirements shall be performed
within 30 days after the re-start of the affected unit
v. The Permittee shall follow the startup or shutdown requirements as given in Table 3 to the Subpart for
each coal-fired EGU and comply with all applicable requirements in§63.10011(g).
w. If the Permittee elects to average emissions consistent with §63.10009 for any constituent, following
the compliance date, the Permittee must demonstrate compliance on a continuous basis by meeting
the requirements of paragraphs (a)(1) through (4) of §63.10022. Any instance where the Permittee
fails to comply with the continuous monitoring requirements in paragraphs (a)(1) through (3) of
§63.10022 is a deviation.
x. The Permittee shall determine the fuel whose combustion produces the least uncontrolled emissions,
taking safety considerations into account, i.e., the cleanest fuel, either natural gas or distillate oil, that
is available on site or accessible nearby for use during periods of startup or shutdown. The cleanest
fuel, either natural gas or distillate oil, for use during periods of startup or shutdown determination
may take safety considerations into account.
y. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the continuous
compliance requirements in Sections 2.1 A.16.p through x above are not met.
Monitoring
z. For an affected unit that exhausts to the atmosphere through a single, dedicated stack, the Permittee
shall either install the required CEMS and sorbent trap monitoring systems in the stack or at a
location in the ductwork downstream of all emissions control devices, where the pollutant and
diluents concentrations are representative of the emissions that exit to the atmosphere.
aa. If the Permittee uses an oxygen (Oz) or carbon dioxide (CO2) CEMS to convert measured pollutant
concentrations to the units of the applicable emissions limit, the Oz or COz concentrations shall be
monitored at a location that represents emissions to the atmosphere, i.e., at the outlet of the EGU,
downstream of all emission control devices. The Permittee shall install, certify, maintain, and operate
the CEMS according to 40 CFR Part 75. Use only quality ensured Oz or COz data in the emissions
calculations; do not use Part 75 substitute data values.
bb. If the Permittee is required to use a stack gas flow rate monitor, either for routine operation of a
sorbent trap monitoring system or to convert pollutant concentrations to units of an electrical output-
based emission standard in Table 2 to Subpart UUUUU, the Permittee shall install, certify, operate,
and maintain the monitoring system and conduct on-going quality-assurance testing of the system
according to 40 CFR Part 75. Use only unadjusted, quality-ensured flow rate data in the emissions
calculations. Do not apply bias adjustment factors to the flow rate data and do not use substitute flow
rate data in the calculations.
cc. If the Permittee is required to make corrections for stack gas moisture content when converting
pollutant concentrations to the units of an emission standard in Table 2 to Subpart UUUUU, the
Permittee shall install, certify, operate, and maintain a moisture monitoring system in accordance with

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40 CFR Part 75. Alternatively, for coal-fired units, the Permittee may use appropriate fuel-specific
default moisture values from §75.11(b) to estimate the moisture content of the stack gas. If the
Permittee installs and operates a moisture monitoring system, the Permittee shall not use substitute
moisture data in the emissions calculations.
dd. The Permittee shall use an SO2 CEMS and must install the monitor at the outlet of the EGU,
downstream of all emission control devices, and must certify, operate, and maintain the CEMS
according to 40 CFR Part 75 as specified in paragraphs(f)(1)through(4)of§63.10010.
ee. The Permittee shall use a Hg CEMS or a sorbent trap monitoring system, the Permittee shall install,
certify, operate, maintain and quality-ensure the data from the monitoring system in accordance with
Appendix A to Subpart UUUUU and as specified in §63.10010(g).
ff. The Permittee shall install, certify, operate, and maintain a PM CEMS and record the output of the
PM CEMS as specified in paragraphs(i)(1)through(5)of§63.10010 (shown below). The compliance
limit shall be expressed as a 30-boiler operating day rolling average of the applicable numerical
emissions limit value in Table 2 to Subpart UUUUU.
i. Install and certify the PM CEMS according to the procedures and requirements in Performance
Specification 11—Specifications and Test Procedures for Particulate Matter Continuous Emission
Monitoring Systems at Stationary Sources in Appendix B to 40 CFR Part 60, using Method 5 at
Appendix A-3 to 40 CFR Part 60 and ensuring that the front half filter temperature shall be 160'
±14 °C (3200 ±25 OF). The reportable measurement output from the PM CEMS must be
expressed in units of the applicable emissions limit(e.g.,lb/MMBtu,lb/MWh).
ii. Operate and maintain the PM CEMS according to the procedures and requirements in Procedure
2—Quality Assurance Requirements for Particulate Matter Continuous Emission Monitoring
Systems at Stationary Sources in Appendix F to 40 CFR Part 60.
(A) Conduct the relative response audit(RRA) for the PM CEMS at least once annually(once
per 12-month period).
(B) Conduct the relative correlation audit (RCA) for the PM CEMS at least once every 3
(calendar)years.
iii. Collect PM CEMS hourly average output data for all boiler operating hours except as indicated in
§63.10010(i).
iv. Calculate the arithmetic 30-boiler operating day rolling average of all of the hourly average PM
CEMS output data collected during all nonexempt boiler operating hours.
v. Collect data using the PM CEMS at all times the process unit is operating and at the intervals
specified in §63.10010(a), except for periods of monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities.
(A)Use all the data collected during all boiler operating hours in assessing the compliance with
the operating limit except:

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(I) Any data collected during periods of monitoring system malfunctions, repairs associated
with monitoring system malfunctions, or required monitoring system quality assurance or
quality control activities that temporarily interrupt the measurement of emissions (e.g.,
calibrations, certain audits). Report any monitoring system malfunctions or out of control
periods in the annual deviation reports. Report any monitoring system quality assurance
or quality control activities per the requirements of§63.10031(b);
(II) Any data collected during periods when the monitoring system is out of control as
specified in the site-specific monitoring plan, repairs associated with periods when the
monitoring system is out of control or required monitoring system quality assurance or
quality control activities conducted during out-of-control periods. Report any such
periods in the annual deviation report;
(III)Any data recorded during periods of startup or shutdown.
(B) Record and make available upon request results of PM CEMS system performance audits,
dates and duration of periods when the PM CEMS is out of control to completion of the
corrective actions necessary to return the PM CEMS to operation consistent with the site-
specific monitoring plan.
gg. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the monitoring
requirements in Sections 2.1 A.16.z through ff above are not met.
Recordkeeuing
hh. The Permittee shall keep records of the following:
i. Records required under appendix A and/or appendix B to Subpart UUUUU for continuous
monitoring of Hg emissions.
ii. Each notification and report that is submitted to comply with Subpart UUUUU, including all
documentation supporting any Initial Notification or Notification of Compliance Status or
semiannual compliance report that was submitted, according to the requirements in
§63.10(b)(2)(xiv).
iii. Records of performance stack tests, fuel analyses, or other compliance demonstrations and
performance evaluations, as required in §63.1 0(b)(2)(viii).
ii. For each CEMS,the Permittee shall keep records as follows:
i. Records described in§63.1 0(b)(2)(vi)through(xi).
ii. Previous(i.e., superseded)versions of the performance evaluation plan as required in §63.8(d)(3).
iii. Request for alternatives to relative accuracy test for CEMS as required in§63.8(f)(6)(i).
iv. Records of the date and time that each deviation started and stopped, and whether the deviation
occurred during a period of startup, shutdown, or malfunction or during another period.

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J. For each EGU subject to an emission limit, the Permittee shall keep records of monthly fuel use by
each EGU, including the type(s)of fuel and amount(s)used.
kk. If the Permittee elects to average emissions consistent with §63.10009 for any constituent, the
Permittee must additionally keep a copy of the emissions averaging implementation plan required in
§63.10009(f) ando), all calculations required under §63.10009, including daily records of heat input
or steam generation, as applicable, and monitoring records consistent with §63.10022.
11. If the Permittee chooses to rely on paragraph (1) of the definition of"startup" in §63.10042 for any
EGU,records must be kept of the occurrence and duration of each startup or shutdown.
mm.The Permittee shall keep records of the occurrence and duration of each malfunction of an operation
(i.e.,process equipment)or the air pollution control and monitoring equipment.
nn. The Permittee shall keep records of actions taken during periods of malfunction to minimize
emissions in accordance with §63.10000(b), including corrective actions to restore malfunctioning
process and air pollution control and monitoring equipment to its normal or usual manner of
operation.
oo. The Permittee shall keep records of the type(s) and amount(s) of fuel used during each startup or
shutdown.
pp. The Permittee shall keep records in a form suitable and readily available for expeditious review,
according to §63.10(b)(1). The Permittee shall keep each record for 5 years following the date of each
occurrence, measurement,maintenance, corrective action, report, or record. The Permittee shall keep
each record on site for at least 2 years after the date of each occurrence, measurement, maintenance,
corrective action, report, or record. The Permittee can keep the records off site for the remaining 3
years.
qq. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if the recordkeeping
requirements in Sections 2.1.A.16.hh. through pp. above are not met.
Reporting
rr. The Permittee shall submit the reports required under §63.10031 and, if applicable, the reports
required under appendices A and B to the Subpart. The electronic reports required by appendices A
and B to the Subpart shall be sent to the Administrator electronically in a format prescribed by the
Administrator, as provided in §63.10031. CEMS data (except for PM CEMS and any approved
alternative monitoring using a HAP metals CEMS) shall be submitted using EPA's Emissions
Collection and Monitoring Plan System(ECMPS) Client Tool. Other data, including PM CEMS data,
HAP metals CEMS data, and CEMS performance test detail reports, shall be submitted in the file
format generated through use of EPA's Electronic Reporting Tool, the Compliance and Emissions
Data Reporting Interface, or alternate electronic file format, all as provided for under §63.10031.
ss. The Permittee shall report each instance in which the Permittee did not meet an applicable emissions
limit or operating limit in Tables I through 4 to 40 CFR 63 Subpart UUUUU or failed to conduct a
required tune-up. These instances are deemed violations from the requirements of 40 CFR 63 Subpart
UUUUU and shall be reported according to §63.10031.

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tt. The Permittee shall submit all of the notifications in §§63.7(b) and (c), 63.8 (e), (f)(4) and (6), and
63.9 (b)through(h), as applicable,by the dates specified, or according to an agreed upon schedule by
NCDAQ [§63.9(i)(2)].
uu. When the Permittee is required to conduct a performance test, the Permittee shall submit a
Notification of Intent to conduct a performance test at least 30 days before the performance test is
scheduled to begin.
vv. The Permittee shall submit each report in Table 8 to 40 CFR 63 Subpart UUUUU, as applicable. If
the Permittee is required to (or elect to) continuously monitor Hg and/or HCl and/or HF emissions,
the Permittee shall also submit the electronic reports required under appendix A and/or appendix B to
the Subpart, at the specified frequency.
ww.The Permittee shall submit each report in Table 8 to 40 CFR 63 Subpart UUUUU, as applicable
postmarked on or before January 30 of each calendar year for the preceding six-month period
between July and December and July 30 of each calendar year for the preceding six-month period
between January and June. All instances of deviations from the requirements of this permit must be
clearly identified.
xx. The compliance report shall contain the following:
i. The information required by the summary report located in 63.10(e)(3)(vi).
ii. The total fuel use by each affected source subject to an emission limit, for each calendar month
within the semiannual reporting period, including, but not limited to, a description of the fuel,
whether the fuel has received a non-waste determination by EPA or the basis for concluding that
the fuel is not a waste,and the total fuel usage amount with units of measure.
iii. Indicate whether the Permittee burned new types of fuel during the reporting period. If the
Permittee did burn new types of fuel the Permittee must include the date of the performance test
where that fuel was in use.
iv. Include the date of the most recent tune-up for each EGU. The date of the tune-up is the date the
tune-up provisions specified in §63.10021(e)(6) and(7)were completed.
v. A certification.
vi. If there is a deviation from any emission limit, work practice standard, or operating limit, the
Permittee must also submit a brief description of the deviation, the duration of the deviation,
emissions point identification, and the cause of the deviation.
vii. For each excess emissions occurring at an affected source where the Permittee is using a CMS to
comply with that emission limit or operating limit, the Permittee shall include the information
required in§63.10(e)(3)(v)in the compliance report specified in §63.10031(c).
yy. Each affected source that has obtained a Title V operating permit pursuant to 40 CFR Part 70 or Part
71 shall report all deviations as defined in this subpart in the semiannual monitoring report required
by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If an affected source submits a compliance
report pursuant to Table 8 of Subpart UUUUU along with, or as part of, the semiannual monitoring
report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the compliance report

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includes all required information concerning deviations from any emission limit, operating limit, or
work practice requirement in this subpart, submission of the compliance report satisfies any
obligation to report the same deviations in the semiannual monitoring report. Submission of a
compliance report does not otherwise affect any obligation the affected source may have to report
deviations from permit requirements to the permit authority.
zz. On or after July 1, 2018, within 60 days after the date of completing each performance test, the
Permittee shall submit the performance test reports required by the Subpart to EPA's WebFIRE
database by using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed
through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). The Permittee shall comply with
all applicable requirements in§63.10031(f).
aaa.If the Permittee had a malfunction during the reporting period,the compliance report must include the
number, duration, and a brief description for each type of malfunction which occurred during the
reporting period and which caused or may have caused any applicable emission limitation to be
exceeded.
Observed: The facility became subject to the emission standards and work practice standards beginning
April 16,2016. The facility complies with this requirement by limiting the concentration of mercury to
0.013 lb/GWh based on a 90-day facility average. CEMS are used to measure S02,PM, acid gases, and
Hg emissions as required. Continuous compliance is demonstrated by using all quality-ensured hourly
data recorded by the CEMS and the other required monitoring systems (e.g., flow rate, CO2, 02,or
moisture systems). The facility conducted stack testing for compliance with Subpart UUUUU as part of
the PET testing conducted on Units 1 and 2 (Common Stack 1 (CS 1))on April 13,2021, on Unit 3 on
January 20,2021,and on Unit 4 on January 6,2021. The results were reviewed and accepted by the
SSCB. Per the Mercury and Air Toxics Standard(MATS)compliance report received July 19, 2021, a
sorbent trap monitoring system is used as a back-up monitoring approach should a significant downtime
event occur in the Hg CEMs. The MATS compliance report received on October 29,2021 included 90-
day rolling facility average report for Hg CEMs and downtime reports. The MATS report also indicated
that there were no deviations or excess emissions during the reporting period(July 1,2019 through
September 30,2019). The report was also submitted electronically through EPA's ECMPS database.
Although, semi-annual reporting is required,Duke Energy is submitting the MATS reports on a quarterly
basis to streamline with quarterly reporting. The table below shows the most recent burner inspections
and tune-ups. The tune-ups were within 36 months of the previous ones, except for Unit 3,which was
completed within 30 days of start-up after not being in operation. Compliance is indicated.
Emission Previous Burner Most Recent Burner
Sources Inspections and Inspections and
Tune-up Tune-up
Unit 1 12/7/2018 12/8/2021
Unit 2 12/6/2018 12/10/2021
Unit 3 5/31/2018 8/5/2021
Unit 4 5/29/2018 4/22/2021
17. 15A NCAC 02D .0530(u): USE OF PROJECTED ACTUAL EMISSIONS TO AVOID
APPLICABILITY OF PREVENTION OF SIGNIFICANT DETERIORATION
REQUIREMENTS

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 23
Monitoring/Recordkeeping/Reporting
a. The Permittee has used projected actual emissions to avoid applicability of prevention of
significant deterioration requirements, pursuant to Application 1800073.18B, for the natural gas
co-firing project. The Permittee shall perform the following:
i. The Permittee shall maintain records of annual emissions in tons per year, on a calendar year
basis related to the natural gas co-firing project, for five years following resumption of
regular operations after the change is made.
ii. The Permittee shall submit a report to the Director within 60 days after the end of each
calendar year during which these records must be generated. The report shall contain the
items listed in 40 CFR 51.166(r)(6)(v)(a)through(c).
iii. The Permittee shall make the information documented and maintained under this condition
available to the Director or the general public pursuant to the requirements in 40 CFR
70.4(b)(3)(viii).
iv. The reported actual emissions (post-construction emissions) for each of the five calendar years
will be compared to the projected actual emissions (pre-construction projection) as included
in the current permit.
Observed: All units are now operating partially or fully on natural gas. The facility is keeping
records as required. I observed natural gas records through December 2021. The first report was
received February 26, 2021 for the calendar year 2020. Unit 3 was the only unit on natural gas in
2020. Compliance is indicated.
B. Limestone Receiving, Transfer, Storage, and Processing Equipment:
Limestone train unloading facility(ID No. ES-6 (RUL)), two limestone rail unloading hoppers
(ID Nos. ES-6a(RULa)and ES-6b (RULb)), 60 inches wide limestone unloading belt feeder no.
A (ID No. ES-7 (LUBFA)), 60 inches wide limestone unloading belt feeder no. B (ID No. ES-8
(LUBFB)), and associated baghouse (ID No. CD-RULBF),
48 inches wide limestone unloading conveyor(ID No. ES-9 (LCB 1)),
48 inches wide limestone stack out conveyor(ID No. ES-I I (LCB2)),
40 inches wide limestone reclaim grate feeder(ID No. ES-12a(LPR)),
30 inches wide limestone reclaim conveyor(ID No. ES-12b (LCB3)),
30 inches wide limestone plant feed conveyor no. 1 (ID No. ES-14 (LCB4)),
30 inches wide limestone plant feed conveyor no. 2 (ID No. ES-16 (LCBS)),
30 inches wide limestone plant feed conveyor no. 3 (ID No. ES-18a(LCB6a)),
36 inches wide emergency limestone feeder conveyor(ID No. ES-18c (LCB6c)),
limestone wet ball mill no. 1 (ID No. ES-24 (BM I)), and
limestone wet ball mill no. 2 (ID No. ES-25 (BM2)),
Emergency limestone bucket elevator(ID No. ES-18b (ELBE)),
30 inches wide limestone silo fill conveyor no. 1 (ID No. ES-20 (SILCB7)),
30 inches wide limestone silo fill conveyor no. 2 (ID No. ES-21 (S2LCB8)),
limestone storage silo no. 1 (ID No. ES22 (LS 1)),

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 24
limestone storage silo no. 2 (ID No. ES23 (LS2)), and
associated baghouse (ID No. CD-LPTTBF)
Observed: Limestone was not being unloaded during the inspection. However,limestone was being
transferred along the conveying system with no visible emissions.All conveyors are covered. Compliance
is indicated.
1. 15A NCAC 2D .0510: PARTICULATES FROM SAND,GRAVEL,OR CRUSHED STONE
OPERATIONS
The permittee shall not cause, allow,or permit any material in a sand, gravel,or crushed stone
operation to be produced,handled,transported or stockpiled without taking measures to reduce to a
minimum any particulate matter from becoming airborne to prevent exceeding the ambient air quality
standards beyond the property line for particulate matter,both PM10 and total suspended particulates.
The permittee shall control process-generated emissions from conveyors, screens,and transfer points,
such that the applicable opacity standards in 15 A NCAC 2D .0521 and 2D .0524-40 CFR 60,
Subpart 000 are not exceeded.
Observed: There were no visible emissions observed during the inspection. The permittee is in
compliance with the opacity standard.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from limestone rail unloading station(ES-6(RUL)) shall not be more than 20
percent opacity(except during startups, shutdowns, and malfunctions)when averaged over a six-
minute period. To assure compliance, once a month the permittee shall observe the emissions from
the limestone rail unloading station(ES-6(RUL))for any visible emissions above normal. The results
of the monitoring shall be maintained in a logbook. The permittee shall submit a summary report of
the observations semi-annually.
Observed: The rail unloading station was not operating during the inspection. It was previously
stated that the facility receives two trains of limestone per month from March through December, and
limestone is typically not delivered January or February due to problems with freezing temperatures.
The facility is making the monthly observations and keeping the required records. Semi-annual
reports were received on January 21, 2021 and July 19,2021 with compliance indicated. Overall
compliance with this condition is indicated.
3. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART 000
On and after the date on which the performance test is completed,the permittee shall not allow to be
discharged into the atmosphere from any transfer point on belt conveyors or from any other affected
facility any stack emissions that contain particulate matter in excess of 0.05 g/dscm(0.022 gr/dscf)
and exhibit greater than 7 percent opacity. The permittee shall not allow to be discharged into the
atmosphere from any transfer point on belt conveyors or from any other affected facility, fugitive
emissions that exhibit greater than 10 percent opacity. Where any transfer points on belt conveyors or
any other affected facility are enclosed inside a building,the permittee may choose to comply with
the emission standard requirements for building enclosures instead. The permittee shall not allow to
be discharged into the atmosphere from any crusher, at which a capture system is not used, fugitive
emissions that exhibit greater than 15 percent opacity.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 25
Monitoring
Particulate matter emissions from sources ES-6a(RULa),ES-6b(RULb),ES-7(LUBFA), and ES-
8(LUBFB)shall be controlled by fabric filter CD-RULBF,and particulate matter emissions from
sources ES-18b(ELBE),ES-20(SILCB7),ES-21(S2LCB8),ES22(LS1), and ES23(LS2) shall be
controlled by fabric filter CD-LPTTBF. To assure compliance,the permittee shall perform
inspections and maintenance on the fabric filters as recommended by the manufacturer.As a
minimum,the inspection and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and baghouse for leaks; and
ii. an annual internal inspection of the baghouse,fabric filters, and ducting for structural integrity.
The permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the ductwork,
baghouse, and fabric filters are not inspected and maintained.
To assure compliance with the opacity standards, once a month the permittee shall observe the
individual NSPS-affected emission sources subject to an opacity standard,or the buildings/enclosures
housing these sources, for any visible emissions above normal. The permittee shall establish"normal"
for these sources in the first 30 days following the startup of these sources. If visible emissions from
these sources are observed to be above normal,the permittee shall either: (a)immediately shutdown
the source,repair the malfunction, and conduct a follow-up VE observation demonstrating normal
emissions, (b)be deemed to be in noncompliance with 15A NCAC 2D .0524 or(c) demonstrate that
the percent opacity from the emission points of the emission sources in accordance with 40 CFR
60.675 and 15A NCAC 21) .0501(c)(8)is below the limit given in Section 2.1 B.3 (a)(ii), (b), and(c)
of the permit. If the compliance demonstration in(a)or(c)of the permit cannot be made,the
permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0524.
Recordkeeping
The results of all inspection and maintenance activities shall be maintained in a logbook on-site and
made available to an authorized representative upon request.
The results of the visible emission monitoring shall be maintained in a logbook on-site and made
available to an authorized representative upon request. The permittee shall be deemed in
noncompliance with 15A NCAC 2D .0524 if these records are not maintained.
Reporting
The permittee shall submit a semi-annual summary report of the monitoring and recordkeeping
activities.
Observed: The conveyor system was moving limestone during the inspection and no visible
emissions were observed. The permittee is conducting the monthly visual inspections and annual
internal inspections as required and maintaining records. Annual inspections were conducted on the
bagfilters as follows:
Control Device Control Device ID Previous Internal Most Recent Internal
Description Ins ection N Inspection
Bagfilter for Various CD-RULBF September 15,2020 September 17,2021
Limestone Unloading
Bagfilter for various CD-LPTTBF September 15,2020 September 17,2021
Limestone Sources

Duke Energy Carolinas,LLC -Marshall Steam Station
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Page 26
Semi-annual reports were received on January 21, 2021 and July 19, 2021. Compliance is indicated.
C. One 1,000 horsepower,No. 2 fuel oil-fired emergency use water pump ES-26 (EQWP)
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from this source shall not exceed 2.3 lbs/mmBtu heat input. No
monitoring,recordkeeping or reporting is required.
Observed: Compliance with this stipulation was determined during the permit application process.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from this source shall not be more than 20 percent opacity. To assure compliance,
the permittee shall perform a Method 9 test for 1 hour before the source operates more than 1100
hours using No. 2 fuel oil. The permittee shall keep records of the hours and associated dates,when
these sources are in operation using No. 2 fuel oil, and the dates of performance of Method 9 tests.
The permittee shall submit the results of the Method 9 test as a part of their quarterly report described
in Section 2.1 A.7. c. of the permit. All instances of deviations from the requirements of this permit
must be clearly identified.
Observed: There were no visible emissions observed during the inspection. The water pump has not
operated 1100 hours on fuel oil. As a result,testing is not required yet. The unit is tested for about 10
minutes monthly. Records are maintained electronically. Mr. LaSala provided records showing the
hour meter reading on the water pump was 72.2 hours on December 31,2021,when the most recent
service was performed by Carolina Cat. The previous reading was 69.8 hours on December 18,2020,
when a previous service was completed. Compliance is indicated.
3. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(40 CFR
PART 63 SUBPART ZZZZ)
The permittee shall comply with the recordkeeping requirements of§63.10(b)(3) and keep a record of
the applicability determination(which was included as part of the initial notification requirements of
§63.6645(d)previously submitted) on site at the source for a period of 5 years after the determination.
These sources are exempt from the General Provisions(40 CFR Part 60, Subpart A) and from any
other provisions of Subpart ZZZZ.
Observed: According to previous compliance inspection reports,the water pump became operational
on October 21, 2006 and the initial notification was received on November 16,2006. The unit has a
non-resettable hour meter.As noted above,Mr. LaSala provided records showing the hour meter
reading on the water pump was 72.2 hours on December 31,2021,when the most recent service was
performed by Carolina Cat. The previous reading was 69.8 hours on December 18,2020,when a
previous service was completed. Compliance is indicated.
D. One Limestone Storage Pile(ID No. F1)
The limestone storage pile(F1)was observed. The facility was not unloading limestone at the time of this
inspection. This source is only subject to 2D .0540 and 15A NCAC 02D .1100. Compliance is discussion
below in Section 5.A.

Duke Energy Carolinas,LLC -Marshall Steam Station
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E. Two ash storage silos(ID Nos. ES-S1 and ES-S2),
two (dry) flyash truck loading equipment(ID Nos. ES-FTLD1 and ES-FTLD2),and
associated baghouses(ID Nos. CD-S 1 and CD-S2)
two (wet)flyash truck loading equipment(ID Nos. ES-FTLW1 and ES-FTLW2)
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
Emissions of particulate matter from these sources shall not exceed an allowable emission rate as
calculated by the equations in 15A NCAC 2D .0515(a). Particulate matter emissions from the
two ash storage silos (ID Nos. ES-S 1 and ES-S2) and two(dry)flyash truck loading equipment
(ES-FTLD1 and ES-FTLD2) shall be controlled by the bagfilters(CD-S1 and CD-S2). To assure
compliance,the permittee shall perform monthly visual inspection of the system ductwork and
material collection unit for leaks; and an annual(for each 12-month period following the initial
inspection)internal inspection of the bagfilter's structural integrity. The results of inspection and
maintenance shall be maintained in a logbook. The permittee shall submit semi-annual summary
reports of monitoring and recordkeeping activities.
Observed: The facility is conducting the monthly visual inspections and annual internal
inspections as required. A logbook of all inspection and maintenance activities is maintained
onsite. The most recent visual inspection was conducted December 13,2021. The most recent
annual internal inspections are show in the table below. Compliance is indicated.
Control Device Control Device T Previous Internal Most Recent Internal
Description ID Inspection Inspection
Bagfilter for Various CD-S1 October 29,2020 October 28, 2021
Flyash Sources
Bagfilter for Various CD-S2 October 29,2020 October 28,2021
Flyash Sources
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity. To assure
compliance,once a month the permittee shall observe the emission points of these sources for any
visible emissions above normal. The results of the monitoring shall be maintained in a logbook on-
site and made available to an authorized representative upon request. The permittee shall submit a
summary report of the observations each six-month period.
Observed: Flyash was not being loaded at the time of the inspection. The facility is conducting the
monthly visual inspections and recording them in a logbook. I observed the most recent, dated
December 13,2021. As shown in the table in the previous section,the permittee is in compliance with
this section.
F. Four NSPS coal conveyors(ES-CCONV2, ES-CCONV6,ES-CCONV7,and ES-CCONV8)
Observed: The four coal conveyors were in operation at the time of this inspection.
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 28
Emissions of particulate matter from these sources shall not exceed an allowable emission rate as
calculated by the equations in 15A NCAC 2D .0515(a). No monitoring/recordkeeping/reporting is
required for particulate emissions from these sources to assure compliance with this regulation.
2. 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR PART 60
SUBPART Y)
The permittee shall comply with all applicable provisions, including the notification,testing,
reporting,recordkeeping, and monitoring requirements in accordance with NSPS Subpart Y. On or
after the date on which the performance test required to be conducted under 40 CFR 60.8 is
completed,visible emissions shall not be 20 percent opacity or greater except during periods of
startup, shutdown and malfunction.
To assure compliance, once a month the permittee shall observe the emission points of these sources
for any visible emissions above normal. The results of the monitoring shall be maintained in a
logbook on-site and made available to an authorized representative upon request. The permittee shall
submit a summary report of the observations each six-month period.
Observed: Coal was being transferred by conveyors during the inspection with no visible emissions.
The permittee is conducting the monthly visible observations and recording them in a logbook. The
most recent entry was for December 13,2021. Semi-annual reports were received on January 21,
2021 and July 19,2021. Compliance is indicated.
G. One No. 2 fuel oil-fired emergency/blackout protection diesel generator(ES-35 (EmGen)) and one No. 2
fuel oil-fired diesel emergency air compressor(ES-36(AC))
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from these sources shall not exceed 2.3 lbs/mmBtu heat input. No
monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of No. 2
fuel oil in these sources.
Observed: Compliance with this stipulation was determined during the permit application process.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity. To assure
compliance,the permittee shall perform a Method 9 test for 1 hour using a preapproved protocol
before the sources operate more than 1100 hours using No. 2 fuel oil. The permittee shall keep
records of the hours and associated dates,when these sources are in operation using No. 2 fuel oil,
and the dates of performance of Method 9 tests. The permittee shall submit the results of the Method
9 test as a part of the quarterly report described in Section 2.1 A.7.c of the permit. All instances of
deviations from the requirements of this permit must be clearly identified.
Observed: Neither generator was in operation during the inspection. The hours of operation using
fuel oil are less than 1100 hours; 251.0 hours for ES-35 (EmGen)and 272.3 hours for ES-36 (AC).
As a result,testing requirements do not apply at this time. The facility is maintaining electronic
records that indicate the hours of operation. Compliance is indicated.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 29
3. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (40 CFR
PART 63 SUBPART ZZZZ)
The permittee shall meet the initial notification requirements of§63.6645(d). This notification must
be submitted not later than 120 days after the source becomes subject to Subpart ZZZZ and shall
include an applicability determination statement that the source has no additional requirements under
this subpart and explain the basis of the exclusion. The permittee shall comply with the
recordkeeping requirements of§63.10(b)(3). These sources are exempt from the General Provisions
(40 CFR Part 60, Subpart A) and from any other provisions of Subpart ZZZZ.
Observed: It was noted during a previous inspection that the generator became operational on April
25, 2005 and the compressor became operational on May 23, 2005. The initial notification for these
sources was received on June 1, 2006, which is within 120 days of startup of the sources. The units
have non-resettable hour meters. The facility appeared to be in compliance.
H. One flyash transfer silo (ES-TSU3&4) and associated bagfilter(TSVF)
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
Emissions of particulate matter from these sources shall not exceed an allowable emission rate as
calculated by the equations in 15A NCAC 2D .0515(a). Particulate matter emissions from the two
flyash transfer filter separators(ES-FS3B and ES-FS4B) shall be controlled by the bagfilters(CD-
FS3B and CD-FS4B), and particulate matter emissions from the flyash transfer silo(ES-TSU3&4)
shall be controlled by the bagfilter(CD-TSVF). To assure compliance,the permittee shall perform a
monthly visual inspection and an annual internal inspection of the bagfilters. The results of inspection
and maintenance shall be maintained in a logbook on-site. The permittee shall submit a summary
report of monitoring and recordkeeping activities each six-month period.
Observed: The facility is conducting the monthly visual inspections and annual internal inspections
as required. A logbook of all inspection and maintenance activities is maintained onsite. The most
recent visual inspection occurred on December 19,2019 for all associated bagfilters. Annual internal
inspections are shown in the following table. Semi-annual reports were received on January 21,2021
and July 19, 2021. Compliance is indicated.
Control Device Description Control Previous Internal Most Recent Internal
Device ID Inspection Inspection
Bagfilter for flyash silo TSVF September 17, 2020 September 15,2021
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity. To assure
compliance,once a month the permittee shall observe the emission points of these sources for any
visible emissions above normal. The results of the monitoring shall be maintained in a logbook on-
site. The permittee shall submit a summary report of the observations each six-month period.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 30
Observations: The area was in operation with no visible emissions observed. The facility is
conducting the monthly observations as required.All activities are recorded in a logbook. Semi-
annual reports were received on January 21,2021 and July 19,2021. Compliance is indicated.
I. One 100 kW No. 2 Fuel Oil-Fired Emergency Generator Located at Landfill(ID No. ES-37 (EmGenLF))
1. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from this source shall not be more than 20 percent opacity.
Monitoring/Recordkeeping/Reporting
No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel
oil in this source.
Observations: The generator was not in operation. Compliance is indicated.
2. 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR PART 60
SUBPART IIII)
The permittee shall comply with all applicable provisions, including the notification,testing,
reporting,recordkeeping, and monitoring requirements in accordance with NSPS as promulgated in
40 CFR Part 60, Subpart IIII.
Monitoring/Recordkeeping
- The engine must use diesel fuel with sulfur content of less than 15 ppm
- The engine must be equipped with a non-resettable hour meter.
- If the emergency generator(ID No. ES-37 (EmGenLF))is equipped with diesel particulate filter
to comply with the emission standards,the permittee shall install backpressure monitor on diesel
particulate filter that notifies the permittee when the high backpressure limit of the engine is
approached.
- The permittee must operate and maintain the engine in accordance with the manufacturer's
written instructions.
- The owner of an engine for 2007 or later must comply by assuring that the engine purchased is
certified to meet the applicable emissions standards.
- An emergency engine may be operated for maintenance and readiness checks for up to 100 hours
per year.
- No initial notification is required for an emergency use engine. However,the permittee must
keep records of all the operation of the engine in emergency and non-emergency service that are
recorded through the non-resettable hour meter,unless the engine is shown to meet the standards
applicable to non-emergency use engines.
- If the emergency stationary Cl ICE of emergency generator(ES-37 (EmGenLF))is equipped with
diesel particulate filter,the permittee shall keep records of any corrective action taken after the

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
Page 31
backpressure monitor has notified the permittee that the high backpressure limit of the engine is
approached.
Observations: The facility is using fuel with a sulfur content of less than 15ppm and the generator
has a non-resettable hour meter.As previously stated,the generator does not have a particulate filter.
The generator is Tier II certified and is a 2010 model year engine. The generator is tested
approximately 20 minutes weekly. According to the electronic log,the engine has 223.4 hours of run
time,with 10.1 hours being in 2021. Compliance is demonstrated.
3. 15A NCAC 2D .1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY [40 CFR 63
SUBPART ZZZZ]
The permittee shall meet the requirements of NESHAP Subpart ZZZZ for emergency use stationary
RICE of generator(ES-37(EmGenLF))by meeting all applicable requirements of NSPS Subpart 1111
for compression ignition engine.
Observations: The facility is in compliance with NSPS Subpart 1111. Therefore,the generator is also
in compliance with NESHAP Subpart ZZZZ.
J. One MS4 DSI ACI Storage silo (ES-U4ACISilo) and associated ACI storage silo bin vent filter baghouse
(CD-U4ACISiloBf)
Observations: This equipment was installed in 2015. The permittee submitted initial notification of the
ACI Storage silo start up on May 12,2016. Activated carbon is not being used at the facility and I
observed that these sources were not in operation during the inspection.
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
Monitoring/Recordkeeping/Reporting
Particulate matter emissions from the MS4 DSI ACI storage silo(ES-U4ACISilo) shall be controlled
by the bagfilter(CD-U4ACISiloBf). To assure compliance,the permittee shall perform monthly
visual inspection of the ductwork and annual(12 months from initial inspection)internal inspection
of the bagfilter. The results of inspection and maintenance shall be maintained in a logbook. The
permittee shall submit a semi-annual report.
Observed: The permittee is maintaining records of visual inspections. The previous internal
inspection was conducted on April 20, 2020. These silos are empty and not in use. Semi-annual
reports were submitted on January 21,2021 and July 19,2021. Compliance is indicated.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity. To assure
compliance, once a month the permittee shall observe the emission points of these sources for any
visible emissions above normal. The results of the monitoring shall be maintained in a logbook. The
permittee shall submit a semi-annual summary report of the observations.
Observed: These silos are empty and not in use. Semi-annual reports were submitted on January 21,
2021 and July 19,2021. Compliance is indicated.

Duke Energy Carolinas,LLC -Marshall Steam Station
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K. wastewater treatment facility lime storage silo(ID No. ES-WWTF Silo)with associated bin vent filter(ID
No. CD-WWTF-Silo-BF)
1. 15A NCAC 02D .0510: PARTICULATES FROM SAND,GRAVEL,OR CRUSHED STONE
OPERATIONS
a. The Permittee shall not cause, allow, or permit any material to be produced,handled,transported or
stockpiled without taking measures to reduce to a minimum any particulate matter from becoming
airborne to prevent exceeding the ambient air quality standards beyond the property line for
particulate matter,both PM10 and total suspended particulates.
b. Fugitive non-process dust emissions shall be controlled by 15A NCAC 02D .0540.
c. The Permittee shall control emissions from conveyors, screens, and transfer points, such that the
applicable opacity standards in Section 2.I.K.2.a of the permit are not exceeded.
Testing
d. If emissions testing is required,the testing shall be performed in accordance with General Condition
JJ. If the results of this test are above the limits given in Section 2.LK.2 of the permit,the Permittee
shall be deemed in noncompliance with 15A NCAC 02D .0510.
Monitoring
e. Particulate matter emissions from this source(ID No.ES-WWTF Silo)shall be controlled by the
associated bin vent filter(ID No.CD-WWTF-Silo-BF). To ensure compliance,the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's
inspection and maintenance recommendations,as a minimum,the inspection and maintenance
requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii. An annual(for each 12-month period following the initial inspection)internal inspection of the bin
vent filter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0510 if the ductwork and bin
vent filter are not inspected and maintained.
Recordkeeping
f. The results of inspection and maintenance in Section 2.LK.l.e of the permit shall be maintained in a
logbook(written or electronic format)on-site and made available to an authorized representative upon
request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bin vent filter;and
iv. Any variance from manufacturer's recommendations,if any,and corrections made.

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The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0510 if these records are not
maintained.
Reporting
g. The Permittee shall submit a summary report of the monitoring and recordkeeping activities by January
30 of each calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June.All instances of
deviations from the requirements of this permit must be clearly identified.
Observed: These sources were put into use in March 2019.The facility is conducting monthly visual
inspections as required(when there are daylight deliveries). The most recent was conducted November
30,2021;there were no daylight deliveries in December.The most recent internal inspection was
conducted on January 28,2021;the previous inspection was conducted on January 29,2020.The
semiannual reports were received on January 21,2021 and July 19,2021 with compliance indicated.
Compliance with this condition is indicated.
Note:There is no ducting of the material from the delivery trucks.They unload by hose connections and
piping. The unloading activity is observed by the truck driver and the visible emissions are noted by plant
personnel.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from this source shall not be more than 20 percent opacity(except during startups,
shutdowns, and malfunctions)when averaged over a six-minute period. However, six-minute averaging
periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-
hour period. In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with 15A NCAC 02D .2601
and General Condition JJ. If the results of this test are above the limits given in Section 2.1.K.2.a,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring
c. To assure compliance, once a month the Permittee shall observe the emission points of this source(ID
No. ES-WWTF Silo)for any visible emissions above normal. The Permittee shall establish"normal"for
the source in the first 30 days following start-up of the sources. If visible emissions from this source are
observed to be above normal,the Permittee shall either: (a)immediately shutdown the source and repair
the malfunction,(b)be deemed to be in noncompliance with 15A NCAC 02D .0521 or(c)demonstrate
that the percent opacity from the emission points of the emission sources in accordance with 15A NCAC
02D .2601 for 30 minutes is below the limit given in Section 2.1.K.2.a above. If the demonstration in(c)
above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D
.0521.
Recordkeeping
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;

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ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30
of each calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
Observed: These sources were put into use in March 2019.The facility is conducting monthly visual
inspections as required(when there are daylight deliveries). The most recent was conducted November
30,2021;there were no daylight deliveries in December. There were no deliveries occurring at the time
of the inspection. Semiannual reports were received on January 21,2021 and July 19,2021 with
compliance indicated. Compliance with this condition is indicated.
L. Three natural gas-fired,natural gas supply line heaters(ID Nos. ES-HTR1, ES-HTR2, and ES-HTR3)
Note: Currently, only unit 3 (ID No. ES-3) is operating on natural gas. According to Mr. LaSala, there is
one heater in use as primary,with the others being in standby, and they cycle through as primary. He says
that when more units are brought online with natural gas as the primary fuel, all heaters will be in full use.
1. 15A NCAC 02D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of natural gas that are discharged from these sources
(ID Nos.ES-HTR1,ES-HTR2 and ES-HTR3)into the atmosphere shall not exceed 0.081 pounds per
million Btu heat input.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for emissions of particulate matter from the firing of
natural gas in these sources(ID Nos. ES-HTR1,ES-HTR2 and ES-HTR3)to demonstrate compliance
with 15A NCAC 02D.0503.
Observed:No monitoring/recordkeeping/reporting is required.These sources were installed,and startup
was November 16,2020.
2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.

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Testing
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of natural
gas in these sources.
Observed:No monitoring/recordkeeping/reporting is required.These sources were installed,and startup
was November 16,2020.
3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity(except during
startups, shutdowns, and malfunctions)when averaged over a six-minute period. However, six-
minute averaging periods may exceed 20 percent not more than once in any hour and not more than
four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas
from these sources.
Observed:No monitoring/recordkeeping/reporting is required.These sources were in use with no visible
emissions at the time of the inspection Compliance was indicated.
4. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(40 CFR PART 63, SUBPART DDDDD)
Applicability
a. For new sources without a continuous oxygen trim system and with heat input capacity of less than
10 million Btu per hour,but greater than 5 million Btu per hour,in the Unit designed to burn gas I
subcategory,the Permittee shall comply with all applicable provisions,including the monitoring,
recordkeeping, and reporting contained in Environmental Management Commission Standard 15A
NCAC 02D .1111 "Maximum Achievable Control Technology" (MALT) as promulgated in 40 CFR
63, Subpart DDDDD "National Emission Standards for Hazardous Air Pollutants for Major Sources:
Industrial, Commercial, and Institutional Boilers and Process Heaters" [Subpart DDDDD] and
Subpart A"General Provisions".
i. The Permittee shall comply with Subpart DDDDD upon startup.
Definitions and Nomenclature
b. For the purpose of this permit condition,the definitions and nomenclature contained in 40 CFR
63.7575 shall apply.

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40 CFR Part 63 Subpart A General Provisions
c. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A General Provisions
according to the applicability of Subpart A to such sources as identified in Table 10 to Subpart
DDDDD.
Compliance Date
d. The Permittee shall comply with this subpart upon startup of the process heaters.
Notifications
e. The Permittee shall submit an initial Notification of Compliance Status. The notification shall
contain the following:
i. A description of the affected unit(s)including identification of which subcategories the unit is in,
the design heat input capacity of the unit, and description of the f iel(s)burned.
ii. The following certification of compliance:
"This facility completed the required initial tune-up for all of the boilers and process heaters
covered by 40 CFR part 63 subpart DDDDD at this site according to complies with the required
initial tune-up according to the procedures in§63.7540(a)(10)(i)through(vi)."
The notification must be signed by a responsible official and must be submitted within 60 days of the
compliance date.
Observed: These sources were installed,and startup was November 16,2020. The Notice of
Compliance Status and notification of startup were received on December 1,2020.Compliance was
indicated.
General Compliance Requirements
f At all times the affected unit(s)is operating,the Permittee shall be in compliance with the emission
standards in Section 2.1.L.4.g of the permit, except during periods of startup and shutdown.
g. At all times,the Permittee shall operate and maintain any affected source(as defined in §63.7490),
including associated air pollution control equipment and monitoring equipment, in a manner
consistent with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used will be based on
information available to the Administrator that may include,but is not limited to,monitoring results,
review of operation and maintenance procedures,review of operation and maintenance records, and
inspection of the source.
Work Practice Standards
h. The Permittee shall conduct a biennial tune-up of the source(s)as specified below.
i. As applicable, inspect the burner, and clean or replace any components of the burner as
necessary. The Permittee may perform the burner inspection any time prior to the tune-up or
delay the burner inspection until the next scheduled or unscheduled unit shutdown;
ii. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame
pattern. The adjustment should be consistent with the manufacturer's specifications, if available;

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iii. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly(the Permittee may delay the inspection until the next
scheduled unit shutdown);
iv. Optimize total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available, and with any NOx requirement to which the unit is
subject; and
v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by
volume, and oxygen in volume percent,before and after the adjustments are made(measurements
may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments
are made).Measurements may be taken using a portable CO analyzer.
i. The Permittee shall demonstrate initial compliance with the applicable work practice standards in
Table 3 to this subpart within the applicable biennial schedule as specified in§63.7515(d) following
the initial compliance date. Thereafter,the applicable biennial tune-up is required to be completed as
specified in§63.7515(d).
j. Each biennial tune-up shall be conducted no more than 25 months after the previous tune-up.
k. If the unit is not operating on the required date for a tune-up,the tune-up must be conducted within 30
calendar days of startup.
Observed: These sources were installed and started up on November 16,2020.According to Mr.
LaSala,the heaters have been put on a schedule for tune-up according to the startup date.Compliance
will be determined when the tune-up is due.
Recordkeeping Requirements
1. The Permittee shall:
i. Keep a copy of each notification and report submitted to comply with Subpart DDDDD,
including all documentation supporting any Initial Notification or Notification of Compliance
Status,or compliance report that has been submitted.
ii. Maintain on-site and submit, if requested by the Administrator,the tune-up report containing the
information in paragraphs(A)through(C)below:
A. The concentrations of carbon monoxide in the effluent stream in parts per million by volume,
and oxygen in volume percent,measured at high fire or typical operating load,before and
after the tune-up of the boiler or process heater;
B. A description of any corrective actions taken as a part of the tune-up; and
C. The type and amount of fuel used over the 12 months prior to the tune-up,but only if the unit
was physically and legally capable of using more than one type of fuel during that period.
Units sharing a fuel meter may estimate the fuel use by each unit.
m. The Permittee shall:
i. Maintain records in a form suitable and readily available for expeditious review;

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ii. Keep each record for 5 years following the date of each occurrence,measurement,maintenance,
corrective action,report, or record; and
iii. Keep each record on site for at least 2 years after the date of each occurrence,measurement,
maintenance, corrective action,report, or record. The Permittee can keep the records offsite for
the remaining 3 years.
Observed: The facility is keeping records as required. Compliance is indicated.
Reporting Requirements
n. The Permittee shall submit a biennial compliance report to the DAQ.
i. The first compliance report shall be postmarked on or before January 30,2021 and cover the
period from May 20,2019 through December 31, 2020.
ii. The compliance reports shall also be submitted electronically to the EPA via the procedures in
§63.7550(h).
o. The compliance report must contain the following information:
i. Company name and address;
ii. Process unit information, emissions limitations, and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. Include the date of the most recent tune-up for each unit required according to Section 2.LF.5.g.
of the permit. Include the date of the most recent burner inspection if it was not done as scheduled
and was delayed until the next scheduled or unscheduled unit shutdown; and
v. Statement by a responsible official with that official's name,title, and signature, certifying the
truth, accuracy, and completeness of the content of the report.
Observed: The first compliance report was received on January 21, 2021 and covered the period
from start up through December 31,2020.
M. Natural gas supply line pigging operation including fugitive emissions from pig receiver vent(ID
No. ES-PIGGING) with associated temporary flare of natural gas from supply line (ID No. CD-
PIG FLARE)
Note: According to Mr. LaSala, these sources will only be used during pipeline condensate cleaning and
removal activities, which will not be necessary very often (estimating every 5 to 7 years), because the
pipeline is dedicated just for the power plant's use.
1. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.

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Testing
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of natural
gas in these sources.
Observed:No monitoring/recordkeeping/reporting is required.These sources were installed and
notification that natural gas was connected to these sources was received October 27,2020.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity(except during
startups, shutdowns, and malfunctions)when averaged over a six-minute period. However, six-
minute averaging periods may exceed 20 percent not more than once in any hour and not more than
four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas
from these sources.
Observed:No monitoring/recordkeeping/reporting is required.These sources were not in operation at
the time of the inspection.No issues were noted. Compliance is indicated.
M. Coal pile and coal handling (ID No. ES-COALFUG) and Ash landfills and ash handling (ID No.
ES-ASHLFFUG)
See Sections 5.A.1, 5.B.1, 5.C.1 below.
5. Section 2.2-Multiple Emission Source(s) Specific Limitations and Conditions
A. Limestone Receiving,Transfer, Storage,and Processing Equipment:
limestone train unloading facility(ES-6(RUL)),two limestone rail unloading hoppers(ES-6a(RULa) and
ES-6b(RULb)), 60 inches wide limestone unloading belt feeder no. A(ES-7(LUBFA)), 60 inches wide
limestone unloading belt feeder no. B (ES-8(LUBFB)), and associated baghouse(CD-RULBF),
48 inches wide limestone unloading conveyor(ES-9(LCB1)),48 inches wide limestone stackout
conveyor(ES-11(LC132)),40 inches wide limestone reclaim grate feeder(ES-12a(LPR)), 30 inches wide
limestone reclaim conveyor(ES-12b(LCB3)), 30 inches wide limestone plant feed conveyor no. 1 (ES-
14(LCB4)), 30 inches wide limestone plant feed conveyor no. 2 (ES-16(LCB5)), 30 inches wide
limestone plant feed conveyor no. 3 (ES-1 8a(LCB6a)), 36 inches wide emergency limestone feeder
conveyor(ES-18c(LCB6c)), limestone wet ball mill no. 1 (ES-24(BM1)), and limestone wet ball mill no.
2 (ES-25(BM2)),

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emergency limestone bucket elevator(ES-18b(ELBE)),30 inches wide limestone silo fill conveyor no. 1
(ES-20(S1LC137)), 30 inches wide limestone silo fill conveyor no. 2 (ES-2 1(S2LCB8)),limestone storage
silo no. 1 (ES22(LS1)), limestone storage silo no. 2 (ES23(LS2)), and associated baghouse(CD-
LPTTBF)
one limestone storage pile(F 1)
Coal pile and coal handling(ID No. ES-COALFUG) and Ash landfills and ash handling(ID No. ES-
ASHLFFUG)
1. 15A NCAC 2D .0540: PARTICULATES FROM FUGITIVE NON-PROCESS DUST
EMISSION SOURCES
The facility is required to operate the facility such that fugitive non-process dust emissions do not
cause or contribute to substantive complaints.
Observed: There have been no substantive complaints received by the MRO about dust emissions
since the last inspection. The facility uses water trucks on the haul roads. The facility appeared to be
in compliance with this regulation at the time of this inspection.
B. Facility Wide Toxics Demonstration
STATE-ONLY REQUIREMENT
1. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. Pursuant to 15A NCAC 02D .1100 and in accordance with the approved application for an air
toxic compliance demonstration,the limits given in the permit shall not be exceeded.
Monitoring/Recordkeeping/Reporting
b. No monitoring,recordkeeping, or reporting shall apply to any emission sources included in
Section 2.2 B.La. of the permit.
Observed: A previous modeling analysis was conducted and received May 22,2018 as part of an
application (1800073.18A) to construct the new flue gas desulfurization wastewater treatment
plant (WWTP). Additionally, under a separate application (1 800073.18B) and accompanying
modeling analysis received October 3, 2018, the facility proposed to modify the Title V Air
Permit(03676T56)to add natural gas co-firing capability to boiler units 1 through 4. The WWTP
and co-firing project modeling analyses were revised to address NC DAQ comments emailed to
Duke on November 7, 2018 that questioned the basis of wind erosion emissions modeled from
on-site storage piles. Therefore, both the WWTP and co-firing projects net increase in toxic air
pollutant (TAP) emissions were evaluated together under the revised dispersion modeling
analysis received March 18, 2019. The air toxics modeling analysis of facility-wide TAP
emissions adequately demonstrated compliance with Acceptable Ambient Levels (AALs)
outlined in 15A NCAC 02D.1104,on a source-by-source basis.Compliance is indicated.

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STATE-ONLY REQUIREMENT
2. 15A NCAC 02Q .0711: EXISTING FACILITES AND SIC CALLS for TOXIC AIR
POLLUTANT EMISSIONS LIMITATION REQUIREMENT
a. As of May 3,2019 emissions of toxic air pollutants have been demonstrated on a facility-wide
basis (excluding those sources exempt under 15A NCAC 02Q .0702 "Exemptions")that each of
the toxic air pollutants(TAPS) emitted from all sources at the facility are either below its
respective toxic permit emission rates(TPER)listed in 15A NCAC 02Q .0711 - "Emission Rates
Requiring a Permit" or the TAPS are in compliance with 15A NCAC 02D .1100 "Control of
Toxic Air Pollutants" as described elsewhere in this permit.
b. The facility shall be operated and maintained in such a manner that any new, existing, or
increased actual emissions of any TAP listed in 15A NCAC 02Q .0711 or in this permit from all
sources at the facility(excluding those sources exempt under 15A NCAC 02Q .0702
'Exemptions"), including fugitive emissions and emission sources not otherwise required to have
a permit,will not exceed its respective TPER listed in 15A NCAC 02Q .0711 without first
obtaining an air permit to construct or operate.
c. PRIOR to exceeding any of the TPERs listed in 15A NCAC 02Q .0711,the Permittee shall be
responsible for obtaining an air permit to emit TAPS and for demonstrating compliance with the
requirements of 15A NCAC 02D .1100 "Control of Toxic Air Pollutants".
d. The Permittee shall maintain at the facility records of operational information sufficient for
demonstrating to the Division of Air Quality staff that actual TAPs are less than the rate listed in
15A NCAC 02Q .0711.
e. The TPER table listed in the current permit is provided to assist the Permittee in determining
when an air permit is required pursuant to 15A NCAC 02Q .0711 and may not represent all TAPs
being emitted from the facility. The table will be updated at such time as the permit is either
modified or renewed.
Observed: All recently installed sources have been accounted for in the permit. The facility has not
added any additional equipment. The facility maintains records of TAP emissions. Compliance is
indicated.
C. One No.2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx
concentric firing system,separated overfire air/lowered fired low-NOx technologies
(SOFA/LOFIR),and alkaline-based fuel additive(ID No.ES-1) and associated selective non-
catalytic reduction system(SNCR)NOx reduction system (ID No. CD-lc(UISNCR)), sulfur
trioxide flue gas conditioning system(ID No. CD-2),electrostatic precipitator(ID No. CD-3),
and wet flue gas desulfurization system consisting of spray tower absorber(ID No. CD-
U1/2FGD)
One No. 2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx
concentric firing system,separated overfire air/lowered fired low-NOx technologies
(SOFA/LOFIR), and alkaline-based fuel additive(ID No.ES-2) and associated selective
non-catalytic reduction system(SNCR)NOx reduction system(ID No. CD-4c(U2SNCR)),
sulfur trioxide flue gas conditioning system(ID No. CD-5), electrostatic precipitator(ID
No. CD-6), and wet flue gas desulfurization system consisting of spray tower absorber(ID
No. CD-Ul/2FGD)

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One No. 2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx
concentric firing system,separated overfire air/lowered fired low-NOx technologies
(SOFA/LOFIR), and alkaline-based fuel additive(ID No.ES-3) and associated selective
catalytic reduction system(SCR)NOx reduction system(ID No. CD-7c(SCR)),
electrostatic precipitator(ID No.CD-9 (ESPnew)), and wet flue gas desulfurization system
consisting of spray tower absorber(ID No. CD-U3FGD)
One No. 2 fuel oil/natural gas/coal-fired electric utility boiler equipped with a low NOx
concentric firing system,separated overfire air/lowered fired low-NOx technologies
(SOFA/LOFIR), and alkaline-based fuel additive(ID No.ES-4) and associated selective
non-catalytic reduction system(SNCR)NOx reduction system(ID No. CD-1Ic
(U4SNCR)),sulfur trioxide flue gas conditioning system(ID No. CD-12),powdered
activated carbon system(ID No. CD-U4ActC),electrostatic precipitator(ID No. CD-13
(ESPnew)), and wet flue gas desulfurization system consisting of spray tower absorber(ID
No. CD-U4FGD)
Three natural gas-fired, natural gas supply line heaters (ID Nos. ES-HTR1,ES-HTR2
and ES-HTR3)
Natural gas supply line pigging operation including fugitive emissions from pig receiver
vent(ID No. ES-PIGGING)with associated temporary flare of natural gas from supply
line (ID No. CD-PIG FLARE)
Coal pile and coal handling (ID No. ES-COALFUG) and Ash landfills and ash handling
(ID No. ES-ASHLFFUG)
1. 15A NCAC 02Q .0504: OPTION FOR OBTAINING CONCTRUCTION AND OPERATION
PERMIT
Permitting
a. Pursuant to 15A NCAC 02Q .0501(b)(2)or(c)(2),for completion of the two-step significant
modification process initiated by Application No. (1800073.1813),the Permittee shall file an amended
application following the procedures of Section 15A NCAC 02Q .0500 within one year from the date
the first of these sources(ID Nos. ES-1 through ES-4,ES-HTR1,ES-HTR2,ES-HTR3 or ES-
PIGGING)begins to burn natural gas.
Reporting
b. The Permittee shall notify the Regional Office in writing of the date of beginning of burning natural
gas in these sources(ID Nos.ES-1,ES-2,ES-HTR1,ES-HTR2,ES-HTR3,ES-PIGGING,ES-
COALFUG and ES-ASHLFFUG),postmarked no later than 30 days after such date.
Observed:Notices were received on October 27, 2020 and December 1,2020 for sources ES-
PIGGING and heaters ES-HTR1, ES-HTR2, ES-HTR3,respectively. The notices were both within
30 days of the beginning of burning natural gas in each source. Sources ES-COALFUG and ES-
ASHLFFUG have not been constructed yet. Compliance will be determined after construction. The
part II application for these sources was received September 29,2021. Compliance is indicated.

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6. Section 2.3 -Permit Shield for Non-Applicable Requirements
This condition is to clarify that issuance of this permit provides no shield from the Act, or regulations
promulgated thereunder, including state regulations,pertaining to requirements of the New Source
Performance Standards or major or minor new source preconstruction review requirements,which EPA is
currently alleging or may allege in the future as having been violated by the permittee. The permit may be
subject to reopening to include a compliance plan and schedule addressing any judicial or administrative order
establishing new applicable requirements arising out of past or ongoing noncompliance with those provisions
for any affected emission units.
The Permittee is shielded from the non-applicable requirements listed in the permit as of the date of issuance
of the current permit based on information furnished with all previous applications. This shield does not apply
to future modifications or changes in the method of operation.
7. Section 2.4-Phase II Acid Rain Permit Requirements
Statutory and Regulatory Authorities: In accordance with the provisions of Article 2 1 B of Chapter 143,
General Statutes of North Carolina as amended and Titles IV and V of the Clean Air Act,the Department of
Environment Quality, Division of Air Quality issues this permit pursuant to Title 15A North Carolina
Administrative Codes, Subchapter 2Q .0400 and 2Q .0500, and other applicable Laws.
The permit applications were submitted by the facility as follows:
Acid Rain Permit Application dated January 27,2016
Phase 11 NOx Compliance Plan dated June 23,2015
Phase II NOx Averaging Plan dated June 23,2015
The applications were approved by the Department of Environmental Quality,Division of Air Quality. The
owners and operators of these Phase II acid rain sources must comply with the standard requirements and
special provisions set forth in the applications.
8. Part I-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 -GENERAL CONDITIONS
A Condition B. - The permittee is required to maintain a copy of the permit and application at the facility.
Observed: The permit and application were available at the facility.
B. Condition D. - The permittee is required to submit two copies of all documents, reports, test data, and
monitoring data to MRO. Observed: The company historically has submitted two copies of all
correspondence. All CEM's data is submitted to the Stationary Source Compliance Branch in RCO.
C. Condition F. —The permittee is required to operate and maintain the facility at all times in a manner that
will effect an overall reduction in air pollution. Observed: The facility is currently performing the
required inspections and maintenance of all the control devices to ensure proper performance and
maximum control for the facility.
D. Condition I.—The permittee is required to report any excess emissions and permit deviations. Observed:
The facility did not report any excess emissions since the last inspection.

Duke Energy Carolinas,LLC -Marshall Steam Station
January 12,2022
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E. Condition O. - The permittee is required to retain records of all required monitoring data and supporting
information for a period of at least five years from the date of the monitoring sample, measurement,
report, or application. Observed: The facility is maintaining these records.
F. Condition P. - The permittee is required to submit an annual compliance certification by March 1 for the
preceding calendar year. Observed: The last certification was received on February 24, 2021 for
calendar year 2020.
G. Condition X. - The permittee is required to submit an emissions inventory by June 30 of each year.
Observed: The MRO received the inventory for calendar year 2020 on June 23, 2021 (via AERO).
Certification forms and supporting calculations were received June 28,2021.
H. Condition CC. — The permittee is required to service, repair, and maintain any refrigeration equipment
which use Class I or 11 ozone-depleting substances according to the work practices,personnel certification
requirements, and certified recycling and recover equipment specified in 40 CFR Part 82, Subpart F.
Observed: The facility maintains a logbook that contains the amount of refrigerant used and in which
refrigeration unit it is used. Mr. Tolbert maintains copies of the personnel certifications.
I. Condition DD. - This facility does not appear to be subject to the requirements of the Chemical Accident
Release Prevention Program, Section 112(r)of the Clean Air Act.
9. The following non-permitted air emission sources and control devices were observed as follows.
A variety of insignificant activities were observed at the time of this inspection and no visible emissions or
problems were noted.
10. Other compliance requirements and issues:
According to Mr. LaSala,the facility is storing 2,250-gallon totes of PFAS containing fire fighting foam until it can
be replaced with an alternative that is PFAS-free.
11. Summary of changes needed to the current permit:
None.
12. Compliance assistance offered during the h�pection:
None
13. Based on my observations, this facility appeared to be in compliance with the applicable air quality
regulations at the time of the inspection.
MJW:Ims
cc: MRO File
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